| April 9,2015 HAZMAT ROB |
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| I have always felt that it is not what you say, but what you don’t say that is important. The same could be said for selecting containers for your shipments of hazardous materials and waste. Just because a packaging is authorized does not mean that particular packaging can be used for your material. Sometimes it’s the authorized container you don’t choose that’s more important than the one you do choose. There is a big difference between an authorized container and the correct container.
SPEC VS POPS YOU, NOT THEM HEADSPACE COMPATIBILITY FOR EXAMPLE, A FLAMMABLE When your material is a Class 3 Flammable liquid, DOT authorizes both plastic and steel drums. Section 173.202 authorizes the use of both of 1A1/1A2 closed and open head steel and 1H1/1H2 closed and open head plastic drums for flammable liquid, n.o.s. To be honest, I would feel comfortable using either steel or plastic containers if my material were just a flammable liquid. The reason being that most flammable liquids do not react unfavorably with plastic or steel. CORROSIVE But be careful; if your material is a Class 8 Corrosive, the DOT regulations could also authorize the exact same 1A1/1A2 steel and 1H1/1H2 plastic drums. This is because per Column 8A of the 172.101 Hazardous Materials Table, DOT authorizes the same plastic or steel drums under 173.202 for both Flammable Liquid, n.o.s., which is Class 3, and Corrosive Liquid, n.o.s., which is Class 8. So most shippers might assume that the same steel and plastic drums could always be used for both materials. That may not be the case. STEEL OR PLASTIC The shipper may be authorized to use the same steel or plastic containers for both materials. But the containers may not be compatible with both materials. What if the authorized steel or plastic drums were not compatible with the corrosive? The container, even though it is authorized in Column 8A and 173.202, would only be appropriate for both materials if neither type of container failed. However, if the steel drum holding the corrosive material were to fail or suffer from “corrosivity, permeability, softening, premature aging and embrittlement” because of its corrosive characteristic, it seems that then, and only then, would the shipper be in violation for not using the correct container for the material. MIXED CONTENTS Seminar attendees often ask which chemicals can be shipped together in the same outer packaging. It can be difficult to say, and DOT will only say that “hazardous materials may not be packed or mixed together in the same outer packaging with other hazardous or nonhazardous materials if such materials are capable of reacting dangerously with each other and causing combustion or dangerous evolution of heat, evolution of flammable, poisonous, or asphyxiant gases, formation of unstable or corrosive materials.” CLOSURE Did you know most steel drum closures require a torque wrench? So, without the correct equipment, how would the shipper ensure the container was “closed that under conditions including the effects of temperature, pressure and vibration normally incident to transportation there is no identifiable release of hazardous materials to the environment’ and that “the closure is leakproof and secured against loosening? INSPECTIONS When a container fails, it must be reported per 49 CFR 171.16. This incident report will be sent to DOT. A local DOT inspector will then most likely schedule an appointment to review the shipper’s hazardous materials documentation, including training records, manufacturer’s closure instructions and closure equipment (torque wrench) for the container that failed. PACKAGING ENFORCEMENT The inspector will also ask the shipper for the documentation used to determine the material’s hazard class(es) and specific gravity. The shipper will then be asked to explain the process used to determine the proper containers. Finally, the inspector will asked the shipper to show what information was used to determine the container was compatible with the material it contained. SHIPPING DOCUMENTATION Most shippers do not realize they are required to maintain manufacturer’s closure instructions. You must train and test your employees on the proper selection, filling and closing of containers. Shippers must keep closure instructions one year for single containers and two years when using combination containers. The container manufacturer’s name or symbol can be found at the end of the required manufacturer markings displayed on the side of each container. WORK WITH SUPPLIER Before you ship any hazardous materials or waste, it would certainly pay to spend some time with the manufacturer of your containers to ensure that the containers are compatible with the specific materials that are being shipped. The manufacturer should have some guidelines or recommendations. If my supplier or manufacturer could not tell me if the container was compatible with my material, based on the liability, I would have to look to a different supplier who could provide that information. NERVOUS NELLIE I get nervous when asked to help in the selection of containers. I am never really sure the person asking knows what they are shipping. Then I am not always sure that the person filling and closing the container has been trained and has the right equipment to close it properly. I find it is safer sometimes to tell the shipper which authorized containers they should not use, rather than which ones they should. So, if you know what your material is, but are not sure which containers you should use, you are not alone. If you give us a call, and we can, at the very least, tell you which containers not to use. Thank you for your readership and support. |
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